Critics have repeatedly alleged that executives routinely take advantage of the many loopholes that exist regarding Rule 10b5-1 trading plans to engage in improper conduct. These.
On March 3, 2023 the Department of Justice (“DOJ”) announced its Compensation Incentives and Clawbacks pilot program (the “Program”), which will become effective March 15, 2023..
Dept of Justice March 15, 2023 guidelines incl the preservation of business-related communications on employees phones computers, incl compliance related criteria into execs compensation bonus structures, fine reductions for corps if they seek to clawback compensation paid to executive wrongdoers
On February 22, 2023, the Department of Justice announced a new Voluntary Self-Disclosure Policy (the Disclosure Policy) that now governs corporate prosecutions by US Attorney’s Offices.
On February 22, 2023, the United States Department of Justice (“DOJ”) issued the United States Attorney’s Offices’ Voluntary Self-Disclosure Policy (the “VSD Policy”) for corporate.